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Numerous OSHA standards contain requirements for employee training. Typically, these standards state “the employer must provide training to affected employees”, or similar language. Obviously, your FULL TIME EMPLOYEES are going to have to be trained, but there are some other "categories" of employees you should not overlook.
NEWLY HIRED EMPLOYEES must be trained in all applicable OSHA standards BEFORE they are exposed to the hazards. Unfortunately, some companies provide a quick “safety orientation” that covers very little of the required training, thinking that the new worker will get “caught up” during regularly scheduled training classes over the coming months. Take the time to do a proper, thorough orientation for the newbies.
PART TIME EMPLOYEES must also be trained in situations where employee training is required. Just because they do not work 40 hours a week does not mean they are exempt from OSHA training.
TEMPORARY SERVICE EMPLOYEES must also receive all required safety training. OSHA typically holds the “client” (end user) responsible for providing "site-specific" training for employees on the hazards and procedures to work safely at their place of work, even if the temp service company provides generic training. Pay careful attention to the temp service contract language regarding worker training responsibilities to insure nothing is omitted or forgotten.
WORKERS ON THE NIGHT SHIFT is one more category that often gets overlooked when it comes to employee safety training. I have audited companies in the past that had excellent employee safety training programs, but only for the first shift; the late shift workers were more or less ignored.
MANAGEMENT PERSONNEL may need to be included in your employee safety training efforts too, where applicable. Oftentimes, I find the “floor level” workers thoroughly trained, yet the FOREMEN AND SUPERVISORS (who have the same exposures) did not attend the training classes (doing paperwork, I guess).
OFFICE WORKERS are often overlooked when it comes to OSHA training, too. The secretary or QA inspector may stay in the office most of the time, but they still need training on applicable topics, such as emergency action plans and evacuation routes. And if those employees go onto the shop floor or construction site on occasion, they must be trained for the hazards to which they are exposed (PPE use/requirements come to mind as one example).
WORKERS ON SICK LEAVE, VACATION, PERSONAL LEAVE, or LAY-OFF often get overlooked for scheduled OSHA training when they return to work. Implement a mechanism to make sure those workers receive all required training they missed as soon as they return to work.
TRANSFERRED EMPLOYEES who get moved into a new job (permanently, or even to fill in for a absent co-corker) may need some additional safety training on hazards and procedures specific to their new work area. Often times, the worker may have exposures to different chemical or equipment hazards that could require additional training, as well as different safety policies or procedures for the new work area (such as a different evacuation procedure or specific location for the MSDS’s . . .) that require additional training.
EMPLOYEES OPERATING NEW EQUIPMENT cannot be overlooked either. A worker may have been trained and evaluated on a particular brand and model of forklift. But if he or she is required to operate a different brand or model (due to transfer and/or new equipment), there may be a need for a little “hands on” demonstration, practice, and evaluation on the new model.
EMPLOYEES EXPOSED TO NEWLY INTRODUCED HAZARDS, such as those working in a revamped work operation where new chemicals, equipment, and/or machinery are provided, may need some additional training, as well.
What other “employee” categories can you think of that I may have overlooked?
My next post to this blog will address a proposed change to the OSHA requirement for reporting injuries to that agency. And PLEASE, pass a link to this blog to anyone else you know who may benefit from this information.
